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                             October 17, 2023

       Dave Chan Ming
       Chief Executive Officer
       SU Group Holdings Ltd
       Unit 01     03, 3/F, Billion Trade Centre
       31 Hung To Road, Kwun Tong
       Kowloon, Hong Kong

                                                        Re: SU Group Holdings
Ltd
                                                            Amendment No. 3 to
Draft Registration Statement on Form F-1
                                                            Submitted September
29, 2023
                                                            CIK No. 0001969863

       Dear Dave Chan Ming:

            We have reviewed your amended draft registration statement and have
the following
       comments.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

               After reviewing the information you provide in response to this
letter and your amended
       draft registration statement or filed registration statement, we may
have additional comments.

       Amendment No. 3 to Draft Registration Statement on Form F-1

       PRC Approvals, page 7

   1.                                                   We note your disclosure
that you "have not experienced denials in obtaining permissions
                                                        or approvals and have
complied with the applicable laws and regulations in all material
                                                        respects." The
disclosure here should not be qualified by materiality. Please make
                                                        appropriate revisions
to your disclosure. In addition, revise to clarify whether you have
                                                        received all requisite
permissions or approvals, as your disclosure only explicitly states
                                                        that you have not
received any denials.
 Dave Chan Ming
FirstName LastNameDave
SU Group Holdings Ltd Chan Ming
Comapany
October 17,NameSU
            2023   Group Holdings Ltd
October
Page 2 17, 2023 Page 2
FirstName LastName
Risk Factors
The PRC legal system is evolving rapidly and the PRC government exerts
substantial
influence..., page 32

2.       We note your revised disclosure in response to comments 6 and 9.
Please further revise
         this risk factor to remove your references to "oversight" and restore
your prior    influence
         or discretion    language. Alternatively, explain how oversight is
different in this context,
         or provide a more detailed description of what you mean by
oversight.
       Please contact Taylor Beech at 202-551-4515 or Donald Field at
202-551-3680 with any
questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Trade
& Services
cc:      Richard Anslow, Esq.